How I would improve LPFM

In my previous article, I have touched on my "proposed" LPFM service. Since the recent Report and Order that established the ground rules for last October's window as well as eliminated LP-10 and rejected the concepts for a 50 and 250 watt LPFM service and based on the outcome of the October (November) filing window, I have drawn up a plan to improve LPFM.

This concept is within the limitations of the Local Community Radio Act (LCRA). It would even be better if certain provisions of the LCRA were repealed.

Here's what I would like to see:

73.807 Minimum distance separation between stations.
Spacing between LPFM stations and all classes of FM broadcast stations should be done through contour overlap. In order to comply with the LCRA, in addition to the contour overlap, full power stations would be required to be spaced by specific distances. At the time the LCRA was enacted, the FCC had both LP-100 and LP-10 tables on the books. I would use the LP-10 table as the minimum required spacing between LPFM and full service FM. There would be no LP-10 minimum distance separation between LPFM and other LPFM stations, FM translators or foreign stations.

No changes to the second adjacent channel rules.

125 km Mexico "strip zone" rule would be codified in the rules.

As long as the LP-10 minimum is met for protection to full service FM stations, allow provisions that permit contour overlap if the contours only overlap over water or if there is terrain shielding between the two stations, especially in the case of LPFM to LPFM spacing.

73.811 LPFM power and antenna height requirements.
Implement maximum service similar to the translator rules. Stations east of the Mississippi as well as Zone I-A (California, Puerto Rico & Virgin Islands) can operate up to 250 watts at 32 meters HAAT (7.3 km service contour). All other stations can operate up to 250 watts at 107 meters HAAT (13.3 km service contour). The minimum service allowed is 10 watts at 32 meters HAAT (3.2 km service contour).

73.813 Determination of antenna height above average terrain (HAAT)
For all new authorizations and changes, use 12 radials instead of 8.

73.816 Antennas
Allow the use of directional antennas for all stations (not just public safety and second adjacent channel waivers).

73.825 Protection to TV channel 6
Until a new method for digital television is ever developed, use the contour overlap model similar to translators to protect full power, Class-A and TV translator stations operating on Channel 6.

73.870 Processing of LPFM broadcast station applications
Allow minor moves to any location where the service contours of the current LPFM facility and the proposed facility overlap.

73.871 Amendment of LPFM broadcast station applications
Allow minor moves to any location where the service contours of the current LPFM facility and the proposed facility overlap.

73.872 Selection procedure for mutually exclusive LPFM applications
Change the minimum of 8 hours of local programming per day to one-third of the hours the station broadcasts in a calendar day. This will give relief to the stations that will be time sharing.

While many of these proposed changes will require more substantial engineering work, it is for the better of LPFM as it offers the most flexibility while staying within the limitations of the LCRA.